About the Compliance Division
The Compliance Division is responsible for leading AFME work on Conduct of Business and Regulatory Structure issues in the UK - including matters relating to firms' relationships with FSA - through both direct representations to the relevant authorities and through overseeing the activities of relevant working groups which report to it. Its work is led by heads of compliance from AFME members, who also participate in the work taken forward by the specialist groups established to deal with cross-cutting issues, including EU work and other international initiatives. The Division also often works jointly with other associations.
Key Issues and Initiatives
The Division aims to achieve the optimum regulatory framework for Members' business through close dialogue with the Authorities on issues regulatory of structure and rules; also on issues relevant to firms' relationships with regulators (principally the FSA). The Division concentrates on the following work streams:
Regulatory/legal structure (see also the Regulatory Structure page)
- Future supervisory arrangements in Europe, FSB/G-20 initiatives sections;
- Turner review/CP-non-prudential elements, including aspects of Conservative Party proposals;
- Walker review/governance and remuneration;
- Banking Act resolution regime - market safeguards; and
- Possible Special Insolvency Regime for investment firms in the UK; Treasury consultation; and other post-Lehman workstreams.
Relationship with regulators
- Practical implications of FSA's Supervisory Enhancement Programme and operation of ARROW, including Compliance resources;
- FSA's approach to enforcement (currently, in particular, CP on fines policy; also joint work on firm-commissioned reports);
- Implications of FSA's principles-based regulation approach, including role of guidance and Dear CEO letters; and
- FSA's approach to CBA and the Better Regulation initiative more generally.
Dialogue on rules
- Approved Persons Regime and T&C developments;
- Aspects of FSA client money rules/diversification;
- Controllers and Close links reporting requirements;
- MiFID implementation and review - various, in particular, conduct of business rules;
- Short selling requirements/disclosure regime; and
- Framework for FSA Periodic Fees and FSCS levies.
Organisation
Compliance Division initiatives are generated by the members, approved by the Compliance Committee, and carried out by AFME staff with input from various working groups of the divisions. The Compliance Committee also participate in the work taken forward by the AFME working groups established to deal with cross-market issues, including EU work and other international initiatives.
Working Groups
Acquisitions/Controllers
Banking Reform
Client Money/Diversification
Data Protection
AFME is also a member of the Joint Associations Committee on Structured Products and acts as secretary to the Financial Services and Markets Legislation City Liaison Group.
Contact
Peter Beales, Managing Director
peter.beales@afme.eu
+44 (0)20 7743 9309
Recent Documents
6 August 2010
Joint Response to CESR Technical Advice to the European Commission in the context of the MiFID Review - Client Categorisation
22 June 2010
Joint AFME, APCIMS, BBA & FOA Response to CP10/7: Taping: Removing the mobile phone exemption
23 March 2010
MIFID Review: Briefing Paper by AFME, APCIMS, FOA and ISDA
5 March 2010
EFSA's view on the DG Markt's suggestion to categorise any client as retail for very complex products 
22 December 2009
Joint AFME/ ICMA/ FOA Response to CESR Consultation on Inducements 
14 December 2009
Joint AFME/ FOA Response to CESR's Consultation on Understanding the Definition of Advice under MiFID 
30 November 2009
Joint AFME/ ICMA Response to CESR's Consultation on Guidance on Registration Process, Functioning of Colleges, Mediation Protocol, Information set out in Annex II, Information set for the Application of Certification and for the Assessment of CRAs' Systematic Importance 
23 October 2009
Financial Services and Markets Legislation City Liaison Group Response to FSA Consultation Paper 09/19, "Enforcement Financial Penalties" 
22 July 2009
LIBA Response to 'Developing effective resolution arrangements for Investment Banks', HMT Paper dated May 2009 
Links
16 December 2009
Treasury sets out plans to manage investment bank failures